Policy Owner: Vice President of Academic Affairs
VP/Mission Area/ Cabinet Member: Academic Affairs & College Advancement
Policy Submitter: Katie Morford
Contact Information: kmorford@css.edu, 218-723-6185
Effective Date:
Affected Constituents: Faculty, Staff, Students
I. Background
The College of St. Scholastica is responsible for ensuring that charges to Federal and State grants for employee compensation comply with Federal, State, and Agency regulations and requirements.
I. Purpose
This policy is created so that The College of St. Scholastica (CSS) will be compliant with the regulatory provisions of the Federal Office of Management and Budget including 2 CFR 200, Uniform Guidance. It is intended to provide direction to faculty and staff for determining and documenting the amount of compensation paid to faculty, staff, or student workers
from a Federal or State grant award
III. Definitions
Institutional Base Salary (IBS): The annual salary the College pays an employee. For faculty and staff members not employed on a twelve-month basis, the base salary is what an individual is scheduled to receive for the number of months worked.
IV. Policy
This policy applies to all employees working on Federal or State grant awards. Any Federal or State proposal prepared on behalf of The College of St. Scholastica (CSS) will contain an estimated amount of compensation to be paid to each faculty, staff or student worker (or, in the absence of a named individual, to an identified job position) participating in the grant-funded project.
Consulting work within the College is assumed to be undertaken as a part of normal employment with no compensation in addition to IBS. However, in exceptional circumstances, employees may receive additional compensation at a rate above their IBS for consulting/evaluating work on a Federal or State grant, only if ALL of the following conditions are met:
- The consulting/evaluating work is clearly cross-departmental (generally not within the same School).
- The consulting/evaluation is clearly outside of the individual’s normal College duties.
- The sponsoring agency has provided prior written approval, such as in the Notice of Award, of the extra compensation.
Employees on less than 12-month contracts can be employed for additional time during the summer, up to 12 months in total, if they are paid at no more than the same rate they are paid during the year, proportional to the time worked. Faculty and exempt employees may not receive additional compensation (overload payments) for grant work during the period of their contract.
Additional compensation, which does not exceed the proportional amount of the faculty or exempt employee’s IBS, is allowable for summer work that is outside of the employee’s contract period. All additional pay is subject to agency requirements which may be more restrictive.
Individuals paid 100 percent from Federal or State grant funds cannot perform any additional institutional functions outside of their grant-related job duties unless additional compensation from non-government sources is provided that is commensurate to the additional work. Incidental activities, such as department meetings and college functions, constituting no more than 5% of the employee’s time, are allowable.
Time spent drafting a grant proposal or renewal may not be charged to a Federal or State grant. This work must be completed on unpaid time or time funded by CSS sources. All payroll costs charged to Federal or State grants must be allowable, allocable to the particular grant program, reasonable, and consistent with the College’s other labor and salary practices. Faculty, staff, and student workers are expected to verify and certify that the payroll charges allocated to a Federal or State award are commensurate with the amount of effort expended, as specified in the Grant Compensation Procedure.